ANNA HOLLAND EDWARDS 1 Colorado Bar No. 35811 RACHEL KENNEDY 2 Colorado Bar No. 54038 Holland, Holland Edwards, & Grossman, LLC 3 1437 N. High Street Denver, CO 80218 4 Phone: (303) 860-1331 anna@hheglaw.com 5 Attorneys for Plaintiff, pro hac vice 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 NICOLAI MORK, Case No. 3:21-cv-00077-MMD-CSD 9 Plaintiff, 10 ORDER GRANTING ATTORNEYS' FEES vs. COSTS, AND INTEREST 11 PERRY RUSSELL, et al., 12 Defendants. 13 Plaintiff, by and through counsel, proposes the following Order Granting Plaintiff Post- 14 15 Verdict Attorneys’ Fees, Costs, and Interest, in accordance with the Court’s February 5, 2026 16 Order (ECF 170): 17 I. INTRODUCTION 18 On June 17, 2025, Plaintiff Nicolai Mork proceeded to trial on two Eighth Amendment 19 claims arising from his treatment at Stewart Conservation Camp, a Nevada Department of 20 Corrections facility. Following a three-day trial, the jury awarded Plaintiff $4,347,750.00 in 21 compensatory damages. ECF No. 131. The Court entered judgment in Plaintiff’s favor on June 22 23 20, 2025. ECF No. 133. 24 As the prevailing party, Plaintiff is entitled to to reasonable costs and post-judgment 25 interest. Additionally, for the reasons discussed during the February 5, 2026, hearing on 26 Defendants’ motions for post-trial relief and Plaintiff’s motion for costs, fees, and interest, 27 Plaintiff is also awarded one year pre-judgment interest and post-verdict attorneys’ fees. See ECF 139-143, 153-154, 158-159, 162, 165-167, 170. 1 2 II. PLAINTIFF’S MOTION FOR COSTS IS GRANTED 3 Plaintiff seeks costs as detailed in ECF 139 at pp. 23-24. Plaintiff has expended an 4 additional $730.30 since ECF 139 was filed, as shown in Ex. 1. The costs sought are reasonable. 5 Accordingly, Plaintiff’s Motion for Costs to date in the amount of $32,757.81 is GRANTED. 6 III. PLAINTIFF’S MOTION FOR POST-VERDICT FEES IS GRANTED 7 The Court finds that the rates and hours sought by Plaintiff for post-verdict attorneys’ 8 fees, including for time spent responding to Defendants’ post-verdict motions and raising the 9 10 motion for attorneys’ fees, as detailed in Ex. 2 and Ex. 3, are reasonable and not subject to 11 reduction based on the Prison Litigation Reform Act. See Woods v. Carey, 722 F.3d 1177, 1184 12 (9th Cir. 2013) (holding that the PLRA fee cap does not apply to fees incurred in defending a 13 judgment in favor of a prisoner on appeal). The Court notes that Plaintiff has exercised billing 14 judgment by voluntarily reducing fees in many instances where two or more attorneys 15 participated in the billed work, which further underscores the reasonableness of the lodestar 16 calculations. Plaintiff’s Motion for Post-Verdict Fees in the amount of $125,942.50, to date, is 17 18 GRANTED. 19 IV. PLAINTIFF’S MOTION FOR PRE-JUDGMENT INTEREST IS GRANTED IN PART 20 The decision to award prejudgment interest “under federal law is a matter left to the 21 22 sound discretion of the trial court.” Purcell v. United States, 1 F.3d 932, 942–43 (9th Cir. 1993); 23 see also Western Pacific Fisheries v. SS President Grant, 730 F.2d 1280, 1288 (9th Cir.1984). 24 The Court declines to award pre-judgment interest for the time it took for the Complaint to be 25 screened and proceed through the mediation program, or for the generally expected timeline for 26 cases of this type. However, the Court finds Defendants’ discovery conduct in this matter 27 hearing in this matter, the Court finds that the balance of equities supports an award of one year 1 of prejudgment interest. Accordingly, Plaintiff’s Motion for Prejudgment Interest is GRANTED 2 3 IN PART. Plaintiff is awarded prejudgment interest in the amount of $178,257.75. See ECF 139 4 at pp. 21-22 (discussing applicable T-Bill rate of 4.10%). 5 V. PLAINTIFF’S MOTION FOR POST-JUDGMENT INTEREST IS GRANTED 6 An award of post-judgment interest on a District Court judgment is mandatory and 7 accrues from the date the judgment is entered. 28 U.S.C. § 1961; see Air Separation Inc. v. 8 Underwriters at Lloyd’s of London, 45 F.3d 288, 289–90 (9th Cir.1995) (holding that post 9 10 judgment interest is mandatory, and noting that the “[f]ailure to award post judgment interest 11 would create an incentive for defendants to exploit the time value of money by frivolously 12 appealing or otherwise delaying payment.”). Interest should be awarded on the entire judgment, 13 including any pre-judgment interest and attorneys’ fees. Id. at 291. Accordingly, Plaintiff’s 14 Motion for Post-Judgment Interest on the verdict, one year pre-judgment interest, and post- 15 verdict attorneys’ fees, in the amount of $136,384.99 and continuing to accrue at a rate of 16 $522.55/day, as detailed below, is GRANTED. See ECF 139 at pp. 22-23 (discussing applicable 17 18 T-Bill rate of 4.10%). 19 Post-Judgment Daily Interest Rate 20 (4.10%) 21 One Year Prejudgment Interest $ 178,257.75 $ 20.02 Verdict $ 4,347,750.00 $ 488.38 22 Post-Verdict Fees as of 3/9/26 (261 days) $ 125,942.50 $ 14.15 23 Post Judgment Interest as of 3/9/26 (261 days) $ 136,384.99 $ 522.55 24 25 VI. CONCLUSION 26 Plaintiff is hereby awarded $473,343.05 in fees, costs and interest, to date, on the verdict 27 1 of $4,347,750.00, calculated as follows: 9 HHEG costs $ 29,561.41 $2,794.40 ; $402.0 4 Post-Verdict Fees as of 3/9/26 (261 days) $ 125,942.50 5 One Year Prejudgment Interest $ 178,257.75 Post Judgment Interest as of 3/9/26 (261 days) $ 136,384.99 6 SABIE 8 || Post-judgment interest will continue to accrue at a rate of $522.55 per day until these amounts 9 || are paid. 10 Respectfully submitted this 9th day of March, 2026. 1 By: /s/ Rachel Kennedy 2 RACHEL KENNEDY, Colorado Bar No. 54038 Holland, Holland Edwards, & Grossman, LLC 13 1437 N. High Street Denver, CO 80218 14 rachel@hheglaw.com 15 Attorney for Plaintiff, pro hac vice 16 IT IS SO ORDERED 17 18 DATED this 11th day of March, 2026.
20 Miranda M. Du, U.S. District Judge 21 22 23 24 25 26 27 28
Case 3:21-cv-00077-MMD-CSD MDOocRuKm CenOtS 1T7S8 Filed 03/11/26 Page 5 of 15
Total Costs Sought as of March 9, 2026 7/25/24 Thomas Flynn $ 2 ,000.00 11/15/24 Cert of Good Standing - Dan & Rachel $ 30.00 11/21/24 Veritext - Deposition Transcripts $ 2 ,361.65 12/19/24 Thomas Flynn $ 5 ,520.00 6/15/25 Trial Flights, VRBO $ 4,567.85 7/2/25 Kathy French - Trial Transcript $ 3,200.00 7/2/25 Veritext - Deposition Transcripts $ 7 31.25 7/14/25 Thomas Flynn - Trial Testimony $ 7 ,940.00 7/15/25 Trial Rental Car, Nick Hotel, Nick Flight $ 2 ,480.36 9/15/25 Ninth Circuit Admission $ 4 60.00 2/2/26 February 5, 2026 Hearing Transcript $ 2 70.30 Breeden & Associates Costs (ECF 139.6) $ 2 ,794.40 Nicolai Mork Costs (ECF 139) $ 4 02.00 $ 3 2,757.81 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 6 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 6/23/25 Communications with client 1 6/23/25 Call with Randy Gillmer re post verdict motions and negotiations 6/23/25 RK research fee petition 2 6/23/25 Download & save Doc. 126 0.1 6/23/25 Download & save Docs. 127, 128, 130, 0.2 131, 133 6/23/25 Call with counsel from Stewart v. Write off 0.5 Aranas case 6/23/25 Call with DAG 0.3 Write off 6/23/25 Prejudgment interest research 2 6/23/25 Calls with client, also 6/28, 7/2, 7/9, 0.8 6/24/25 Call with client 0.5 6/24/25 Draft shell of Fee Petition 0.5 6/24/25 Order Trial Transcript from Ms.
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ANNA HOLLAND EDWARDS 1 Colorado Bar No. 35811 RACHEL KENNEDY 2 Colorado Bar No. 54038 Holland, Holland Edwards, & Grossman, LLC 3 1437 N. High Street Denver, CO 80218 4 Phone: (303) 860-1331 anna@hheglaw.com 5 Attorneys for Plaintiff, pro hac vice 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 NICOLAI MORK, Case No. 3:21-cv-00077-MMD-CSD 9 Plaintiff, 10 ORDER GRANTING ATTORNEYS' FEES vs. COSTS, AND INTEREST 11 PERRY RUSSELL, et al., 12 Defendants. 13 Plaintiff, by and through counsel, proposes the following Order Granting Plaintiff Post- 14 15 Verdict Attorneys’ Fees, Costs, and Interest, in accordance with the Court’s February 5, 2026 16 Order (ECF 170): 17 I. INTRODUCTION 18 On June 17, 2025, Plaintiff Nicolai Mork proceeded to trial on two Eighth Amendment 19 claims arising from his treatment at Stewart Conservation Camp, a Nevada Department of 20 Corrections facility. Following a three-day trial, the jury awarded Plaintiff $4,347,750.00 in 21 compensatory damages. ECF No. 131. The Court entered judgment in Plaintiff’s favor on June 22 23 20, 2025. ECF No. 133. 24 As the prevailing party, Plaintiff is entitled to to reasonable costs and post-judgment 25 interest. Additionally, for the reasons discussed during the February 5, 2026, hearing on 26 Defendants’ motions for post-trial relief and Plaintiff’s motion for costs, fees, and interest, 27 Plaintiff is also awarded one year pre-judgment interest and post-verdict attorneys’ fees. See ECF 139-143, 153-154, 158-159, 162, 165-167, 170. 1 2 II. PLAINTIFF’S MOTION FOR COSTS IS GRANTED 3 Plaintiff seeks costs as detailed in ECF 139 at pp. 23-24. Plaintiff has expended an 4 additional $730.30 since ECF 139 was filed, as shown in Ex. 1. The costs sought are reasonable. 5 Accordingly, Plaintiff’s Motion for Costs to date in the amount of $32,757.81 is GRANTED. 6 III. PLAINTIFF’S MOTION FOR POST-VERDICT FEES IS GRANTED 7 The Court finds that the rates and hours sought by Plaintiff for post-verdict attorneys’ 8 fees, including for time spent responding to Defendants’ post-verdict motions and raising the 9 10 motion for attorneys’ fees, as detailed in Ex. 2 and Ex. 3, are reasonable and not subject to 11 reduction based on the Prison Litigation Reform Act. See Woods v. Carey, 722 F.3d 1177, 1184 12 (9th Cir. 2013) (holding that the PLRA fee cap does not apply to fees incurred in defending a 13 judgment in favor of a prisoner on appeal). The Court notes that Plaintiff has exercised billing 14 judgment by voluntarily reducing fees in many instances where two or more attorneys 15 participated in the billed work, which further underscores the reasonableness of the lodestar 16 calculations. Plaintiff’s Motion for Post-Verdict Fees in the amount of $125,942.50, to date, is 17 18 GRANTED. 19 IV. PLAINTIFF’S MOTION FOR PRE-JUDGMENT INTEREST IS GRANTED IN PART 20 The decision to award prejudgment interest “under federal law is a matter left to the 21 22 sound discretion of the trial court.” Purcell v. United States, 1 F.3d 932, 942–43 (9th Cir. 1993); 23 see also Western Pacific Fisheries v. SS President Grant, 730 F.2d 1280, 1288 (9th Cir.1984). 24 The Court declines to award pre-judgment interest for the time it took for the Complaint to be 25 screened and proceed through the mediation program, or for the generally expected timeline for 26 cases of this type. However, the Court finds Defendants’ discovery conduct in this matter 27 hearing in this matter, the Court finds that the balance of equities supports an award of one year 1 of prejudgment interest. Accordingly, Plaintiff’s Motion for Prejudgment Interest is GRANTED 2 3 IN PART. Plaintiff is awarded prejudgment interest in the amount of $178,257.75. See ECF 139 4 at pp. 21-22 (discussing applicable T-Bill rate of 4.10%). 5 V. PLAINTIFF’S MOTION FOR POST-JUDGMENT INTEREST IS GRANTED 6 An award of post-judgment interest on a District Court judgment is mandatory and 7 accrues from the date the judgment is entered. 28 U.S.C. § 1961; see Air Separation Inc. v. 8 Underwriters at Lloyd’s of London, 45 F.3d 288, 289–90 (9th Cir.1995) (holding that post 9 10 judgment interest is mandatory, and noting that the “[f]ailure to award post judgment interest 11 would create an incentive for defendants to exploit the time value of money by frivolously 12 appealing or otherwise delaying payment.”). Interest should be awarded on the entire judgment, 13 including any pre-judgment interest and attorneys’ fees. Id. at 291. Accordingly, Plaintiff’s 14 Motion for Post-Judgment Interest on the verdict, one year pre-judgment interest, and post- 15 verdict attorneys’ fees, in the amount of $136,384.99 and continuing to accrue at a rate of 16 $522.55/day, as detailed below, is GRANTED. See ECF 139 at pp. 22-23 (discussing applicable 17 18 T-Bill rate of 4.10%). 19 Post-Judgment Daily Interest Rate 20 (4.10%) 21 One Year Prejudgment Interest $ 178,257.75 $ 20.02 Verdict $ 4,347,750.00 $ 488.38 22 Post-Verdict Fees as of 3/9/26 (261 days) $ 125,942.50 $ 14.15 23 Post Judgment Interest as of 3/9/26 (261 days) $ 136,384.99 $ 522.55 24 25 VI. CONCLUSION 26 Plaintiff is hereby awarded $473,343.05 in fees, costs and interest, to date, on the verdict 27 1 of $4,347,750.00, calculated as follows: 9 HHEG costs $ 29,561.41 $2,794.40 ; $402.0 4 Post-Verdict Fees as of 3/9/26 (261 days) $ 125,942.50 5 One Year Prejudgment Interest $ 178,257.75 Post Judgment Interest as of 3/9/26 (261 days) $ 136,384.99 6 SABIE 8 || Post-judgment interest will continue to accrue at a rate of $522.55 per day until these amounts 9 || are paid. 10 Respectfully submitted this 9th day of March, 2026. 1 By: /s/ Rachel Kennedy 2 RACHEL KENNEDY, Colorado Bar No. 54038 Holland, Holland Edwards, & Grossman, LLC 13 1437 N. High Street Denver, CO 80218 14 rachel@hheglaw.com 15 Attorney for Plaintiff, pro hac vice 16 IT IS SO ORDERED 17 18 DATED this 11th day of March, 2026.
20 Miranda M. Du, U.S. District Judge 21 22 23 24 25 26 27 28
Case 3:21-cv-00077-MMD-CSD MDOocRuKm CenOtS 1T7S8 Filed 03/11/26 Page 5 of 15
Total Costs Sought as of March 9, 2026 7/25/24 Thomas Flynn $ 2 ,000.00 11/15/24 Cert of Good Standing - Dan & Rachel $ 30.00 11/21/24 Veritext - Deposition Transcripts $ 2 ,361.65 12/19/24 Thomas Flynn $ 5 ,520.00 6/15/25 Trial Flights, VRBO $ 4,567.85 7/2/25 Kathy French - Trial Transcript $ 3,200.00 7/2/25 Veritext - Deposition Transcripts $ 7 31.25 7/14/25 Thomas Flynn - Trial Testimony $ 7 ,940.00 7/15/25 Trial Rental Car, Nick Hotel, Nick Flight $ 2 ,480.36 9/15/25 Ninth Circuit Admission $ 4 60.00 2/2/26 February 5, 2026 Hearing Transcript $ 2 70.30 Breeden & Associates Costs (ECF 139.6) $ 2 ,794.40 Nicolai Mork Costs (ECF 139) $ 4 02.00 $ 3 2,757.81 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 6 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 6/23/25 Communications with client 1 6/23/25 Call with Randy Gillmer re post verdict motions and negotiations 6/23/25 RK research fee petition 2 6/23/25 Download & save Doc. 126 0.1 6/23/25 Download & save Docs. 127, 128, 130, 0.2 131, 133 6/23/25 Call with counsel from Stewart v. Write off 0.5 Aranas case 6/23/25 Call with DAG 0.3 Write off 6/23/25 Prejudgment interest research 2 6/23/25 Calls with client, also 6/28, 7/2, 7/9, 0.8 6/24/25 Call with client 0.5 6/24/25 Draft shell of Fee Petition 0.5 6/24/25 Order Trial Transcript from Ms. French 0.2 6/24/25 Post trial research 3 3 6/24/25 Preparation for and Call with Luke 1 Busby and Lauren Gorman re fee petition, declarations, other cases in the region 6/25/25 PLRA fee petition research 2 6/26/25 AHE consultation with 9th circuit 1 lawyers re pre-trial interest, fee petitions, other civil rights actions 6/26/25 PLRA fee petition 1 6/26/25 RK research PLRA and initial filing 3 6/27/25 Westlaw research on pre judgment 2 interest 6/27/25 Westlaw research RK PLRA 1.3 6/30/25 Westlaw research RK prejudgment 3.3 interest Page 1 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 7 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 7/1/25 Call with Leslie Nino Piro and calls with 0.8 Write off Randy Gillmer, conferral regarding extension 7/1/25 Drafting and filing extension request for 1 0.5 Write off fee petition (Doc. 134) 7/1/25 Download & save Doc. 135 & calendar 0.1 same 7/2/25 RK research other outcomes and fee 1 2 petition research 7/7/25 RK work on fee petition and research 2 4 and drafting 7/8/25 Fee petition 1.5 7/8/25 Download & save Doc. 136-138 0.1 7/10/25 Work on declarations, 7/10-7/11 5 6 7/14/25 Declarations for fee petition 1 7/15/25 Fee petition and exhibits 1 3 7/16/25 Fee petition drafting and editing 2 4 7/17/25 Finalizing calculations, reviewing all 4 4 declarations, editing fee petition, verifying interest rate calculations 7/18/25 Finalizing fee petition, declarations, 3 3 0.5 exhibits 7/18/25 Finalize, file, download & save Docs. 1.5 139 &142 7/18/25 Download & save Docs. 140, 143, 143 0.2 7/21/25 Responding to motions for judgment as 1 4 a matter of law, new trial, and remittitur 7/21/25 Draft, edit, file, download & save Doc. 0.1 0.4 144 7/21/25 Download & save Doc. 145 0.1 Page 2 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 8 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 7/23/25 Responding to motions for judgment as 4 a matter of law, new trial, and remittitur 7/24/25 Download & save Appeal Doc. 2.1, 0.1 calendar deadline 7/24/25 Responding to motions for judgment as 1.5 a matter of law, new trial, and remittitur 7/25/25 Download & save Appeal Doc. 5.1 0.1 7/25/25 Responding to motions for judgment as 3.75 a matter of law, new trial, and remittitur 7/28/25 Responding to motions for judgment as 3 a matter of law, new trial, and remittitur 7/29/25 Responding to motions for judgment as 5.5 a matter of law, new trial, and remittitur 7/30/25 Responding to motions for judgment as 4.25 a matter of law, new trial, and remittitur 8/4/25 Responding to motions for judgment as 4 a matter of law, new trial, and remittitur 8/5/25 Responding to motions for judgment as 5 a matter of law, new trial, and remittitur 8/6/25 Responding to motions for judgment as 6 a matter of law, new trial, and remittitur Page 3 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 9 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 8/7/25 Responding to motions for judgment as 4 a matter of law, new trial, and remittitur 8/8/25 Responding to motions for judgment as 6 a matter of law, new trial, and remittitur 8/8/25 Download & save Appeal Doc. 9.1 0.1 8/11/25 Responding to motions for judgment as 1 5 a matter of law, new trial, and remittitur 8/12/25 Conferral with opposing counsel 0.5 8/12/25 Responding to motions for judgment as 5 a matter of law, new trial, and remittitur 8/13/25 Download & save Appeal Doc. 10.1 & 0.1 calendar same 8/13/25 Call with local counsel 0.5 8/13/25 Research & Draft 9th Circuit Admission 0.3 for Anna 8/13/25 Responding to motions for judgment as 2 5 a matter of law, new trial, and remittitur 8/14/25 Submit Anna Admission to 9th Circuit 0.2 8/14/25 Review, editing, research on responses 6 to motions for judgment as a matter of law, new trial and remittitur 8/14/25 Draft, edit, file, download & save Doc. 0.2 0.5 150 8/14/25 Draft, edit, file, download & save Doc. 0.2 0.5 151 8/15/25 Download & save Doc. 153 0.1 Page 4 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 10 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 8/15/25 Responding to motions for judgment as 1 3 a matter of law, new trial, and remittitur 8/16/25 Responding to motions for judgment as 4 a matter of law, new trial, and remittitur 8/18/25 Responding to motions for judgment as 6 7 a matter of law, new trial, and remittitur 8/19/25 Responding to motions for judgment as 1 2 a matter of law, new trial, and remittitur 8/19/25 Finalize Anna declaration to Response 0.5 to JMOL 8/19/25 Finalize, file, download & save Doc. 2 154 8/19/25 Draft, edit, file, download & save Doc. 0.1 0.3 155 8/20/25 Download & save Doc. 157, file Docs. 1 158 & 159 8/20/25 Ninth Circuit entry of appearance, 1 research for replying to motion for attorneys' fees 8/21/25 Download & save Appeal Doc. 11 & 0.1 calendar same 8/21/25 Mediation call, Ninth Circuit 1 Write off 8/22/25 Research for appeal and reply to 1.5 Write off attorneys' fee petition 8/25/25 Research on PLRA and pre-judgment 3 interest 8/26/25 Research on prejudgment interest 2 Page 5 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 11 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 8/26/25 Download & save Doc. 160 0.1 8/29/25 Replying to motion for attorneys' fees 2 9/1/25 Replying to motion for attorneys' fees 2 9/2/25 Draft, edit & send for signature Erica 0.3 Declaration for attorney fees reply 9/2/25 Finalize and sign Declaration for 0.5 attorney fees 9/2/25 Replying to motion for attorneys' fees 4 7 9/2/25 Finalize, file, download & save Doc. 1 162 9/3/25 Research re enforcing judgment 2 9/8/25 Research re settlement and writ of 0.5 1 execution 9/11/25 Mediation call Write off 1 9/15/25 Download & save Appeal Doc. 12.1 & 0.1 calendar same 9/15/25 Mediation memo research and 1 4 transcript review 9/16/25 Mediation memo research and 1.5 0.5 transcript review 9/16/25 Reviewing reply to JMOL motion 0.5 9/17/25 Mediation statement 0.5 9/18/25 Call with opposing counsel, research 1.5 Write off for appeal 9/19/25 Strategy discussions 0.5 Write off Write off 9/29/25 Mediation statement 3 9/30/25 Mediation statement 0.5 10/1/25 Mediation statement 1 10/10/25 Mediation statement and conferral 1 3.5 10/15/25 Mediation statement 2.5 Page 6 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 12 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 10/16/25 Mediation statement 3 10/20/25 Mediation statement and conferral 0.5 1 10/22/25 Mediation prep 1.5 10/23/25 Mediation 4 4 10/24/25 Download & save Appeal Doc. 13 0.1 1/28/26 Download & save Doc. 168 & calendar 0.1 same 1/29/26 Hearing prep 2 1/30/26 Hearing prep 2 2/2/26 Hearing prep 1 2/3/26 Hearing prep 1 2 2/5/26 Hearing and Hearing preparation 2.3 0.5 1.3 2/5/26 Download & save Doc. 170 2/13/26 Draft, finalize, file, download & save 0.2 0.5 Plaintiff Notice of Appeal 2/18/26 Download & save Pltf Appeal Docs. 1 & 0.1 2, calendar same 2/20/26 Download & save Appeal Doc. 14.1 0.1 2/23/26 Finalize & file Plaintiff Appeal Doc. 3 0.1 1 2/25/26 Download & save Doc. 174 0.1 2/27/26 Draft, finalize, file, download & save 0.5 0.2 Doc. 175 2/27/25 Download & save Appeal Doc. 5, 0.1 calendar same 2/28/26 Download & save Pltf Appeal Doc. 4, 0.1 calendar same 3/2/25 Drafting proposed order 1 3/3/26 Download & save Appeal Doc. 15.1 & 0.1 calendar same 3/3/25 Drafting proposed order 2 Page 7 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 13 of 15 DATE TASK Anna Holland Brooke Thiele- Rachel Emma Richards Erica Edwards LaForest Kennedy Grossman 3/4/25 Reviewing proposed order Write off 3/4/26 Downlad & save Appeal Docs. 16 & 17 0.1
Total Hours 78.3 13.2 176.4 3.5 0.5 Rate $ 600.00 $ 190.00 $ 400.00 $ 75.00 $ 550.00 Total Fees $ 46,980.00 $ 2,508.00 $ 70,560.00 $ 262.50 $ 275.00 Total HHEG fees $120,585.50 Total Breeden & Associates fees (Ex. 3) $5,357.00 Total Attorneys' Fees sought $125,942.50
Page 8 Case 3:21-cv-00077-MMD-CSD Document 178 Filed 03/11/26 Page 14 of 15 Date Person Activity Description Time Rate Billed Adam Breeden 06/22/2025 Adam Breeden Draft Reviewed amended verdict form for N. Mork (Client) re: liability and damages. 0.20 $550.00/hr Write off 06/23/2025 Adam Breeden Review Review of Order regarding Jury Meals. 0.10 $550.00/hr Write off 06/23/2025 Adam Breeden Review/Prepare Review of Judgment 0.20 $550.00/hr Write off 06/23/2025 Adam Breeden Review/Prepare Review of jury verdict filing 0.10 $550.00/hr Write off 06/30/2025 Adam Breeden Draft Review billing, prepare Declaration of counsel under LR 54-14 to support 1.80 $550.00/hr $990.00 07/01/2025 Adam Breeden Meeting Review M inute Ord er in Chambers 0.10 $550.00/hr Write off 07/18/2025 Adam Breeden Draft Review and reply email from A. Edwards (outside co-counsel) regarding 0.40 $550.00/hr Write off 07/18/2025 Adam Breeden Draft Review motion - defendant's request for remittitur by defendants (25 pages) 0.60 $550.00/hr $330.00 07/18/2025 Adam Breeden Draft Review bill of motion document 0.30 $550.00/hr $165.00 07/18/2025 Adam Breeden Review Review Defendants' Motion for New Trial (25 pages) 0.50 $550.00/hr $275.00 07/18/2025 Adam Breeden Review Review Motion -Judgment Defendants' Rule 50(b) Renewed Motion for 0.50 $550.00/hr $275.00 07/18/2025 Adam Breeden Review Review of m ot ion for At torney Fees, Costs and Interest by Plaintiff 0.50 $550.00/hr $275.00 07/21/2025 Adam Breeden Review Review Notice of Appeal by Defendants 0.20 $550.00/hr $110.00 07/21/2025 Adam Breeden Review Review Unopposed motion for extension of time to file response to defendants 0.20 $550.00/hr $110.00 07/22/2025 Adam Breeden Review Rmeovtioenws oef gPalradinintigf fm's oUtnoonp fpoo seudd gMmoetiot n F mor tEioxnte fnosi onne wof Triaml.e to File 0.20 $550.00/hr Write off 07/28/2025 Adam Breeden Draft Review of Ninth Circuit appeal documents 0.20 $550.00/hr $110.00 07/29/2025 Adam Breeden Draft Prepare and efile notice of appearance of counsel in ninth circuit appeal 0.20 $550.00/hr $110.00 07/31/2025 Adam Breeden Draft Review of First UNOPPOSED MOTION Defendants' Unopposed Motion For 0.30 $550.00/hr $165.00 08/13/2025 Adam Breeden Review RExetveineswo On rodfe r i-m Me etdoi aFtiloen Ceospnofenrseen ctoe PSlcahinedtiuflesd M 0.30 $550.00/hr Write off 08/13/2025 Adam Breeden Review Draft correspondence to lead co-counsel regarding scheduling of mediation confer0.1 $550.00/hr Write off 08/13/2025 Adam Breeden Review Review correspondence from A. Edwards (outside co-counsel) regarding 0.10 $550.00/hr $55.00 08/15/2025 Adam Breeden Review Rasesveiseswm eRnets cpoonnseer etnoc Me otion for Attorney Fees by Defendants 0.50 $550.00/hr $275.00 08/15/2025 Adam Breeden Review Review filing granting motions for an extension to file response 0.10 $550.00/hr Write off 08/20/2025 Adam Breeden Review/Prepare Draft correspondence to mediation office regarding telephonic mediation status 0.20 $550.00/hr $110.00 08/22/2025 Adam Breeden Review Rcoenvfieerwe ocfe minutes from trial day 1 0.10 $550.00/hr $55.00 08/26/2025 Adam Breeden Review Review motion to extend time regarding response by defendants 0.30 $550.00/hr Write off 08/27/2025 Adam Breeden Review Review defendant's unopposed motion for extension of time to file replies to 0.10 $550.00/hr Write off 09/06/2025 Adam Breeden Review/Prepare Rpeavinietiwff sd erfeesnpdoannste'ss motion for extension of time to file replies to plaintiff's 0.10 $550.00/hr Write off 09/15/2025 Adam Breeden Review/Prepare Rreesvpioenws ecsorrespondence confirming mediation scheduling 0.10 $550.00/hr $55.00 09/16/2025 Adam Breeden Review/Prepare Review and reply to correspondence from A. Edwards regarding updates in case 0.20 $550.00/hr $110.00 10/24/2025 Adam Breeden Review Review order - mediation released 0.10 $550.00/hr Write off 01/14/2026 Adam Breeden Draft Draft email to co-counsel re status of appeal and settlement 0.20 $550.00/hr $110.00 02/02/2026 Adam Breeden Review Review several emails from the court and counsel re: hearing on outstanding 0.40 $550.00/hr $220.00 ing
Totals for Adam Breeden $5,225.00
update calendar
[Kirsten Brown [Review [Review Filing: Amended Note of Appeal by Defendants Hendason nd [0.10 [8110.00 □□□□□□□□
Totals for Aylssa Piraino and Kirsten Brown $132.00 Pd Pg na ral Total Sf □□□□ 5,357.00